Free Motion for Extension of Time - District Court of Arizona - Arizona

1 2 3 ! 4 5 6 7 8 James John Hadges, 9 10 11 12 13 14 15 16 17 18 19 20 21
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IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA ) ) Plaintiff, ) ) vs. ) ) Maricopa County, a ) political subdivision of ) the State of Arizona; ) Sheriff Joseph Arpaio, as ) elected representative and ) as acting director of ) Maricopa County Sheriff's ) Office; Maricopa Medical ) Center; Correctional ) Health Services, an ) administrative agency of ) Maricopa County, ;Does 1) 10 inclusive; Roe ) Corporations 1-10 ) inclusive, ) ) Defendants. ) __________________________ ) Case No. CIV 04-0259-PHX-EHC

MOTION FOR EXTENSION OF TIME TO RESPOND TO DEFENDANTS' MOTION FOR SUMMARY JUDGMENT

COMES NOW the Plaintiff, James John Hadges, by and

22 through undersigned counsel, and respectfully moves this Court for 23 its order extending the time in which Plaintiff is to respond to 24 Defendants' Motion for Summary Judgment. 25

On February 1, 2007, the Court issued its Order

26 directing Plaintiff to file his response within thirty (30) days. 27 Undersigned counsel has been attempting to schedule a day and time 28 to meet with the Plaintiff to discuss the Defendants' Motion and

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1 the factual allegations therein so that a proper response can be 2 filed.

The first date that counsel could meet with the Plaintiff

3 is February 23, 2007, and the state prison has allocated a maximum 4 of one hour for said meeting.

Obviously, counsel will have to

5 arrange for additional meetings with the Plaintiff in addition to 6 the one hour on February 23. 7

Therefore, in light of the above, Plaintiff requests an

8 extension of at least thirty (30) days in which to file his 9 response. 10

Undersigned counsel has spoken with Deputy County

11 Attorney Maria R. Brandon and she has no objection to this 12 request. 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

RESPECTFULLY SUBMITTED this 22nd day of February, 2007. PHILIP A. SEPLOW, ESQ.

By: s/Philip A. Seplow Philip A. Seplow, Esq. Attorney for Plaintiff

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CERTIFICATE OF SERVICE

X I hereby certify that on February 22, 2007, I electronically transmitted the attached document to the Clerk's Office using the 3 CM/ECF System for filing and transmittal of a Notice of Electronic Filing to the following CM/ECF registrants: 4 Maria R. Brandon, Esq. 5 DEPUTY COUNTY ATTORNEY Attorney for Defendants 6
7

X I hereby certify that on February 22, 2007, I served the attached document by First Class Mail on the following, who are not 8 registered participants of the CM/ECF System:
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

None. S/Philip A. Seplow

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